News & Analysis as of

Threshold Requirements Consumer Financial Protection Bureau (CFPB) Mortgages

Orrick, Herrington & Sutcliffe LLP

CFPB adjusts asset-size exemption thresholds for Regulations C and Z

On December 18, the CFPB adjusted the asset-size exemption thresholds for Regulation C (as part of the Home Mortgage Disclosure Act) and Regulation Z (as part of TILA), based on a 4.1 percent increase in the average...more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

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The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2024 through December 31, 2024, these exemption thresholds are...more

Troutman Pepper

Federal Agencies Announce Increased Regulations Z and M Dollar Thresholds for Exempt Consumer Credit and Lease Transactions, and...

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On November 13, the Consumer Financial Protection Bureau (CFPB) and the Federal Reserve Board (Fed) announced increased dollar thresholds used to determine whether certain consumer credit and lease transactions in 2024 are...more

Ballard Spahr LLP

Federal DC Court Overturns Closed-End Loan HMDA Reporting Threshold

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In April 2020, the CFPB issued a final HMDA rule increasing the Home Mortgage Disclosure Act (HMDA) reporting threshold for closed-end mortgage loans from 25 covered loans originated in each of the prior two years to 100...more

Goodwin

CFPB Issues Reminder of New Threshold for Reporting HMDA Open-End Lines of Credit Data

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In This Issue. The Consumer Financial Protection Bureau (CFPB) reminded institutions of a new threshold for reporting Home Mortgage Disclosure Act data about open-end lines of credit; the Financial Crimes Enforcement Network...more

Ballard Spahr LLP

CFPB Announces No Change in HPML Appraisal Exemption Threshold

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The CFPB recently announced that it, along with the Comptroller of the Currency and Federal Reserve Board, issued a final rule that will maintain the current exemption threshold to the appraisal requirement for higher priced...more

Ballard Spahr LLP

CFPB Updates HMDA Small Entity Compliance Guide

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As previously reported, in April 2020 the CFPB released a final rule to increase the threshold to report closed-end mortgage loans under the Home Mortgage Disclosure Act (HMDA) from 25 to 100 originated loans in each of the...more

Ballard Spahr LLP

CFPB Raises HMDA Reporting Thresholds

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The CFPB recently issued a final Home Mortgage Disclosure Act (HMDA) rule to increase the threshold to report closed-end mortgage loans from 25 to 100 originated loans in each of the prior two years, and to increase the...more

Mayer Brown

Revising the Regulatory Definition of a Qualified Mortgage

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When the federal Consumer Financial Protection Bureau (“CFPB”) last summer issued its Advance Notice of Proposed Rule Making (“ANPR”) to revise the definition of a “Qualified Mortgage” (“QM”) under the Dodd-Frank Act’s...more

Ballard Spahr LLP

2020 HMDA Guide Issued

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The Federal Financial Institutions Examination Council (FFIEC) recently issued the 2020 edition of the Guide to HMDA Reporting: Getting It Right! (2020 Guide)....more

Ballard Spahr LLP

CFPB Updates HMDA Guide

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As previously reported, in October 2019 the CFPB issued a final rule under the Home Mortgage Disclosure Act (HMDA) to...more

Ballard Spahr LLP

CFPB Issues Final HMDA Rule (2019 Update)

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The CFPB recently issued in final form two elements of a May 2019 Home Mortgage Disclosure Act (HMDA) proposed rule. As previously reported, the May 2019 proposal would...more

Ballard Spahr LLP

CFPB/Fed/OCC Increase Exemption Thresholds for Appraisal Requirement, Regs Z and M (UPDATED)

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The CFPB, Fed, and OCC have published notices in the Federal Register announcing that they are increasing three exemption thresholds that are subject to annual inflation adjustments....more

Ballard Spahr LLP

CFPB publishes annual CARD Act, HOEPA, QM adjustments

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The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage...more

Ballard Spahr LLP

CFPB adjusts HMDA data collection, TILA mortgage escrow thresholds

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In notices published in today’s Federal Register, the CFPB adjusted the thresholds of the asset-size exemptions for collecting HMDA data and establishing an escrow account for certain mortgage loans under TILA....more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

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The CFPB, Fed, and OCC have published notices in the Federal Register announcing that they are increasing three exemption thresholds that are subject to annual inflation adjustments. Effective January 1, 2018 through...more

Ballard Spahr LLP

CFPB Issues Update to HMDA Small Entity Compliance Guide

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The Consumer Financial Protection Bureau has issued a second version of the Home Mortgage Disclosure Act (Regulation C) Small Entity Compliance Guide. The updated version incorporates various changes to the HMDA rule that...more

Ballard Spahr LLP

House Financial Services Committee schedules Oct. 11 mark-up of “Madden fix” bill

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Among the more than 20 bills that the House Financial Services Committee is scheduled to mark-up this Wednesday, October 11, is a bill to provide a “Madden fix” as well as several others relevant to consumer financial...more

Ballard Spahr LLP

CFPB updates HMDA rule guidance materials

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The Consumer Financial Protection Bureau (CFPB) recently posted on its website updated versions of guidance in connection with the revisions to the Home Mortgage Disclosure Act (HMDA) rules that become effective on January 1,...more

Ballard Spahr LLP

CFPB Proposes to Temporarily Increase HELOC Reporting Threshold under HMDA

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As we have previously reported, in October 2015 the CFPB adopted significant revisions to the Home Mortgage Disclosure Act (HMDA) rule, most of which become effective January 1, 2018. Among the revisions, the reporting of...more

Ballard Spahr LLP

CFPB announces annual adjustments to HMDA/TILA asset-size exemption thresholds

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The CFPB has announced annual adjustments to two asset-size exemption thresholds. First, the CFPB has made no change to the asset-size exemption threshold under HMDA/Regulation C which is currently set at $44 million. ...more

Ballard Spahr LLP

CFPB amends commentary on adjustments to exemption thresholds; makes no changes to 2017 thresholds

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The CFPB has adopted changes to its Reg Z commentary to memorialize the calculation methods used each year to adjust the thresholds for exempt consumer credit transactions and for transactions exempt from the special...more

Morrison & Foerster LLP

CFPB, OCC, and Federal Reserve Propose Clarifications to Small Loan Exemption from HPML Appraisal Requirements

On August 4, 2016, the Consumer Financial Protection Bureau (“CFPB”), the Office of the Comptroller of the Currency (“OCC”), and the Board of Governors of the Federal Reserve System (“Federal Reserve”) (together, the...more

Ballard Spahr LLP

CFPB Proposes Changes To Higher-Priced Mortgage Loan Exemption Threshold

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The Consumer Financial Protection Bureau (CFPB) published for comment proposed substantive and organizational changes to the Regulation Z Commentary regarding the calculation of the annual exemption threshold amount for the...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

Agencies Issue Proposal on Method to Adjust Threshold for Exempting Small Loans from Special Appraisal Requirements - On July 22, 2016, the Consumer Financial Protection Bureau, the Federal Reserve Board and the Office...more

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